The present rules in the ASME Boiler and Pressure Vessel Code, Section VIII, Division 1, permit design of pressure vessels to temperatures as high as 900F. However, fatigue analysis is required, but the Code does not provide rules for fatigue analysis at temperatures above 700F. New rules are proposed that would provide for exemption from fatigue analysis by satisfaction of an elevated temperature shakedown criteria, in combination with having a limited number of design cycles.